and thus enable verification of the maps. The carrier identified in the <br />application has done so literally hundreds of times in other applications <br />reviewed by CMS. <br /> <br /> <br />3. Evidence demonstrating collocation is impractical on existing tall buildings, light or <br />utility poles, water towers, existing transmission towers, and existing tower facility <br />sites for reasons of structural support capabilities, safety, available space, or failing <br />to meet service coverage area needs. <br /> <br />Comment <br />: To the best of our knowledge there were no structural analyses <br />and reports, spatial reports or safety analyses and reports contained in the <br />application proving that “collocation is impractical” on any existing structure, <br />i.e. that the structure would not accommodate the equipment needed and <br />that, in conjunction with perhaps another [new] facility(s), could serve the <br />intended service area. <br /> <br />Whether within or beyond the 2,000’ radius, it has not been demonstrated <br />by verifiable evidence that an existing tower or other type of support <br />structure cannot be structurally modified to accommodate this provider. The <br />only way to prove that such cannot be done is through a verifiable structural <br />analysis and report (with supporting calculations) of each potential support <br />structure, and/or as applicable an analysis of available space on existing <br />structures. No such analyses and reports have been provided in the <br />application material provided to CMS. <br /> <br />The application also did not contain any technical analysis or explanation <br />regarding the feasibility of “adjusting” or “re-engineering’ the transmission <br />facilities of one or more existing adjacent facilities used by this carrier to <br />serve at least part of the intended service area. Depending upon exactly <br />what is needed to be accomplished by a new facility, sometimes this can <br />decrease the size of a gap in service and thus the needed height of a new <br />facility. Such adjustments can include such matters as increasing the power <br />of one or more sectors, adjusting the direction of the antennas serving one <br />or more sectors, using of higher gain antennas, using a tower-mounted pre- <br />amplifier to boost the return signal from the user’s device. <br /> <br />4. A current overall system plan for the city, showing facilities presently constructed or <br />approved and future expansion plans. <br />5. A statement providing the reasons for the location, design and height of the <br />proposed tower or antennas. <br /> <br /> <br />9.5750(6)(2) and (3) <br />In light of the preceding, it would appear that Subsections of the City’s Code have <br />not been complied with. This is not to state or imply that they will not be met or are not able to be met by <br />this applicant. It is simply to state that to-date there is no evidence of compliance with these <br />requirements. <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />3 <br /> <br />